Backgrounder 2 - Digital Technologies Accessibility Regulations: Current conformance with accessibility standards

Note: This document was originally developed as a public consultation module. It has been updated and reformatted as a backgrounder following the finalization of the Phase 1 Digital Technologies Accessibility Regulations in December 2025 (SOR/2025‑255). For information on the earlier consultation and what we heard from participants, see the Phase 1 consultation.

On this page

• List of abbreviations
• Accessibility standards
• How the finalized digital technologies accessibility regulations are informed by existing standards
• Related information

List of abbreviations

AODA

Accessibility for Ontarians with Disabilities Act

ASC

Accessibility Standards Canada

ATM

Automated teller machine

CSA

Canadian Standards Association

EPT

Electronic payment terminal

ICT

Information and communication technologies

iOS

iPhone operating system

ISO

International Standards Organization

PDF

Portable document format

TBS

Treasury Board of Canada Secretariat

Accessibility standards

Three widely recognized accessibility standards and frameworks that have informed digital accessibility requirements internationally are:

• Web Content Accessibility Guidelines (WCAG)
• Revised Section 508 Standards, and
• Harmonised European Standard accessibility requirements for ICT products and services (EN 301 549) (PDF format, 2.17MB)

Various Canadian banks and financial institutions are also increasingly considering digital technologies accessibility. Online banking and branch transactions are becoming more accessible, especially since the pandemic. In many cases, their web content already meets internationally recognized standards. This includes features like keyboard shortcuts to allow navigation without a mouse or by headings. Some, allow users to change contrast and text size on their web pages, among other features.

ATMs in Canada are becoming more accessible as well. Some now offer audio in English and French. Some ATMs allow audio users to plug headphones into the machine; thereby, the audio direction feature guides users through their transactions. Some ATMs have other accessible design features. These include screens and buttons placed closer to the ground to help wheelchair accessibility. Braille-numbered keypads, large-print and high-contrast keypads and screen text are also common^{Footnote 1}.

Digital technologies vendors and service providers are also taking note of these international standards. Increasingly, they are designing or buying digital technologies that meets some or all of the requirements of these standards. As well, it is common practice for governments to ask digital technologies suppliers and vendors to show how they meet these accessibility standards^{Footnote 2}.

Summary of accessibility standards

Web Content Accessibility Guidelines (WCAG)

WCAG 2.0

• WCAG 2.0 is the single standard for web content across the world
• It includes 12 guidelines grouped under 4 principles, stating that websites must be equally:
• perceivable
• operable
• understandable, and
• robust for all users, regardless of disability or impairment
• Each guideline includes different levels of compliance: A, AA and AAA

WCAG 2.1

• WCAG 2.1 is a newer version of WCAG 2.0 and adds new accessibility criteria (called success criteria) to it
• It adds recommendations for making web content accessible on mobile devices
• It includes additional recommendations to make web content more accessible for persons with:
• blindness and low vision
• deafness and hearing impairment
• limited movement
• speech disabilities
• photosensitivity, and
• combinations of these, as well as some accommodation for learning disabilities and cognitive limitations

Revised Section 508 of the US Rehabilitation Act

• Section 508 is the US standard for digital technologies accessibility since 1998; it was revised in 2017
• It includes requirements for:
• websites and web applications
• native software applications and operating systems
• telecommunications products
• video and multimedia products
• self-contained, closed products (such as multifunction copiers)
• desktops and portable computers, and
• electronic content, including documents, audio, video and multimedia
• The 2017 update to Section 508 added WCAG 2.0 levels A and AA

The European Standard EN 301 549

• Is the European Standard since 2014
• Is closely harmonized with Revised Section 508
• Includes WCAG 2.1 levels A and AA since 2018, and refers to AAA since 2021; adopts WCAG 2.2 in the 2026 version
• Applies to all digital technology, including:
  • hardware
  • websites
  • software
  • non-web documents
  • electronic devices
  • digital technologies built into the environment such as kiosks, and more
• Also touches on the concept of biometrics and support services such as relay service and call centers

Web Content Accessibility Guidelines (WCAG)

The Web Content Accessibility Guidelines are a set of accessibility standards related to web content, non-web documents and software applications when applicable. The WCAG are developed and updated by the World Wide Web Consortium (W3C). This international non-profit organization works with other organizations, persons with disabilities and experts from around the world. Official versions of WCAG 2.0, 2.1 and 2.2 are available in both English and French.

The WCAG are voluntary in most of the world. Some countries, including the United States, United Kingdom and Ireland include some or all the WCAG criteria in their accessibility laws.

Since technology is constantly evolving, WCAG is updated regularly. This ensures its requirements keep up with new developments and innovations in web technologies. These updates are published as different versions, such as WCAG 2.0, WCAG 2.1 and WCAG 2.2.

WCAG 2.0

WCAG 2.0 requires that websites meet the following principles for all users, regardless of level of disability or impairment:

• Perceivable: information and user tools such as keyboards must be made in a way that users can perceive them through at least 1 of their senses
• Example: text alternatives for images and captions for audio content
• Operable: users can interact with and make full use of websites
• Example: replace complex gestures such as pinching and swiping with simpler gestures such as taps and long presses
• Understandable: users should be able to understand information and functions of "user tools"
• Example: make web pages appear and operate in predictable ways
• Robust: content and information on the web must work with a wide variety of user tools, such as assistive technologies
• Example: make websites compatible with assistive technologies such screen readers

WCAG 2.0 has 3 levels of conformance (A, AA and AAA). Each level adds new requirements to the previous level to make products more accessible.

• Level A is the minimum level. Without meeting these basic requirements, barriers exist that result in inaccessible content for persons with disabilities
• This level provides the largest number of people with the most benefits and is essential
• Example: level A requires that web content does not use colour alone to convey meaning^{Footnote 4}. This means, for instance, that a hyperlink needs to be not only a different colour than other text, but also underlined
• Level AA is used in most accessibility rules and regulations around the world. Meeting Level AA criteria may affect the look of a page or the logic of a website to a greater extent
• At this level, content will also work with most assistive technologies.
• Example: level AA further specifies that the contrast between the colour of hyperlinked text and the background of the page must be at least 4.5:1 for normal sized text^{Footnote 5}
• Level AAA deals with specific and specialized circumstances. It is not recommended to be adopted as a general policy for entire sites since it is not always possible to meet all Level AAA requirements for some content^{Footnote 6}
• Example: level AAA requires a colour contrast of at least 7:1 for normal sized text, to ensure that users with more severe vision loss can access the website^{Footnote 7}

WCAG 2.1

WCAG 2.1 builds on WCAG 2.0. It has added criteria that aim at making the web content more accessible for^{Footnote 8}:

• users accessing the web via mobile devices (for example, smartphones)
• low vision users
• cognitive and learning impaired users
• users with motor and visual impairments

For example, 1 of the new criteria in WCAG 2.1 (which is not in 2.0) is regarding additional content that appears and disappears^{Footnote 9}. This requires that content not disappear unless users remove it. This gives people with low vision or learning or cognitive disabilities more time to read the content.

Another new criterion in WCAG 2.1 is about orientation. This means that content must allow portrait and landscape orientations^{Footnote 10}. This is important, for example, for a person with cerebral palsy who uses a wheelchair and has their tablet attached to it. This person must have the option to change display orientation in order to view websites.

Overview of WCAG 2.2

The Web Content Accessibility Guidelines (WCAG) 2.2 build on WCAG 2.1 and 2.0, maintaining the same four foundational principles: that content be Perceivable, Operable, Understandable, and Robust. WCAG 2.2 was published in October 2023 and is primarily an incremental update intended to address specific accessibility barriers, particularly for users with cognitive and learning disabilities, low vision, and limited mobility. Overall, the changes introduced are limited and content that already conforms to WCAG 2.1 will generally require only minor adjustments to align with WCAG 2.2.

Revised Section 508 of the US Rehabilitation Act

Section 508 of the US Rehabilitation Act of 1973 was updated in 2017. The Revised Section 508 requires the US federal government to develop, buy, maintain and use digital technologies that is accessible to persons with disabilities.

Section 508 is intended to ensure US government websites, services and technology are accessible. Among other benefits, this makes it easier for persons with disabilities to apply for federal jobs, for example.

Section 508 also applies to digital technologies used by employees of the US federal government. This means US federal employees with disabilities are able to work using accessible computers, phones and office equipment.

Section 508 incorporates the requirements of WCAG 2.0. This means that all US federal government websites and non-web content and software must meet the Level A and Level AA of WCAG 2.0, with some exceptions^{Footnote 11}.

Section 508 also includes accessibility requirements for:

• software applications and operating systems
• telecommunications products
• desktop and portable computers, as well as products such as copiers, and
• electronic content, including documents, audio, video and multimedia

Digital technology exceptions under Revised Section 508

US government agencies may claim an exception while buying or developing digital technologies items. Allowable exemptions include:

1. Safe harbour for existing compliant digital technologies

The safe harbour exemption may apply when unchanged, existing digital technologies (including electronic content) complies with the original Section 508.

If so, the digital technologies product or service does not have to be modified or upgraded to the Revised Section 508.

2. National security systems

Section 508 requirements might not apply to digital technologies related to:

• intelligence activities
• command and control of military forces
• equipment integral to a weapon or weapons system, or
• systems critical to the direct fulfillment of military or intelligence missions

Note: Exceptions in these areas do not apply to digital technologies used for routine administrative functions in the National security systems, such as payroll and finance.

3. Maintenance and monitoring spaces

This exemption applies to digital technologies located in spaces accessed only for maintenance, repair or occasional monitoring by service personnel.

4. Non-availability of conforming commercial products and commercial services

There may be times when digital technologies product or services that meet Revised Section 508 standards is not available. If so, organizations are allowed to buy the digital technologies that comes closest to meeting the requirements of the Revised Section 508. It should also meet the organizations' business needs.

If an organization uses this exception, it must provide alternative ways for persons with disabilities to access information and data.

Harmonised European Standard Accessibility requirements for digital technologies products and services (EN 301 549)

The Harmonized European Standard EN 301 549 is the most comprehensive standard. It goes beyond web accessibility to cover all digital accessibility. This includes:

• hardware and software
• non-web documents
• electronic devices
• mobile applications
• biometrics^{Footnote 12} (for example, facial recognition, fingerprint detectors)
• and more^{Footnote 13}

The European Standard is updated regularly. The most recent version of the European Standard - the EN 301 549 V4.1.1, released in 2026, adopts Level A and AA of WCAG 2.2 for accessibility of websites, non-web documents and non-web software. Starting in the 2021 version, the European Standard also references level AAA criteria but doesn't require it.

The European Standard is much wider in scope than the WCAG. For example, it also covers:

• orientation of digital technologies: items like reusable plastic smart cards (such as key cards, tickets or fare cards) must allow users to determine their orientation by touch
• For example, a key card must have a raised area or a notch to indicate which way it goes into the card reader
• biometrics: digital technologies that uses biometrics to identify a user must not rely on 1 type of biological characteristic, such as fingerprints
• Some people may have difficulty using fingers or hands
• The ICT must provide alternative biometrics, such as scans for retinal patterns or facial recognition
• hardware: for example, digital technologies hardware that has speech output must include a way to adjust the volume by at least 18 decibels
• This will enable people with mild to moderate hearing impairment to adjust the audio as needed

Sections of the European Standard

Here are some examples of the requirements in the European Standard:

1. Functional performance
1. This section covers the functional performance of digital technologies. This relates to how the ICT requires users to locate, identify, and operate its functions, and access the information provided.
2. For example, if the digital technologies product such as a phone or a computer requires manual actions to use, users with limited hand strength may not be able to perform the action. An alternative that does not require hand strength must be provided.
2. Generic requirements
1. This section explains generic requirements for digital technologies accessibility, including biometrics. For example, the digital technologies may provide speech output as an option for persons who are blind. If so, it must be in the same language as the displayed content.
3. Digital technologies with two-way voice communication
1. This section details accessibility criteria for two-way communication systems. This includes landline and mobile phones, etc.
2. For example, if the ICT provides caller identification, it must be available in text and at least 1 other form, such as voice.
4. Digital technologies with video capabilities
1. This section covers the requirements for digital technologies with video capabilities. It focuses on standards for captioning and audio description.
2. As an example, if the digital technologies shows video with synchronized audio, it must also be able to display the available captions. If closed captioning is provided, the digital technologies must allow the user to choose whether or not to show the captions.
5. Hardware
1. This section covers the accessibility of hardware with speech output, phones and kiosks.
2. For example, many devices, like ATMs, have a rectangular numeric keypad. The number 5 key in the middle of the keypad must have a way for users to find it by touch.
6. Web content, non-web documents and software
1. In this area, the European Standard links directly to the WCAG.
2. There are also additional requirements for closed systems and operating systems which are not a part of WCAG.
7. Documentation and support services
1. This section covers the accessibility of product documentation. It also includes accessibility requirements for support services such as help desks and call centers.
2. As an example, documentation such as manuals that come with the digital technologies must include a list of its accessibility and compatibility features. It must also describe how to use the accessibility features.
8. Digital technologies providing relay or emergency services
1. Relay services enable people who use different methods of communication to interact remotely through digital technologies. This usually involves a human operator. An example would be a service in which a person uses sign language to relay speech from one user to another who has a hearing impairment.
2. This section of the European Standard spells out the accessibility requirements for the digital technologies used for these services. It also sets accessibility standards for the digital technologies which people use to communicate with emergency services.

How the finalized Digital Technologies Accessibility Regulations are informed by existing standards

The Phase 1 Digital Technologies Accessibility Regulations were finalized and published in the Canada Gazette, Part II, on December 17, 2025 (SOR/2025‑255). Requirements for federally regulated entities will apply in stages beginning in 2027 and 2028.

The amendments reference the CAN/ASC-EN 301 549:2024 IDT, which is Accessibility Standards Canada's adoption of the EN 301 549 V3.2.1:2021.

Rationale for selecting the CAN/ASC - EN 301 549

A standards‑based approach provides consistency for federally regulated entities, supports predictable procurement practices, and helps ensure accessible digital technologies for persons with disabilities.

The CAN/ASC-EN 301 549 standard was selected because it is a National Standard of Canada and covers a broad range of digital technologies including websites, digital documents, mobile applications, software, hardware and more.

The CAN/ASC-EN 301 549 standard is technology-neutral and largely outcome-based. This means it does not require organizations to use specific technologies or design approaches. Instead, it sets expectations for accessibility and focuses on ensuring that digital technologies are accessible to persons with disabilities.

As well, it is flexible and regularly updated to keep pace with technological change.

Using an internationally recognized standard also supports consistency across markets, reduces duplication, and helps organizations design accessible products and services that can be used more broadly.

Related information

• Glossary of terms
• Summary version of consultation